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Office of Labor-Management Standards
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Office of Labor-Management Standards (OLMS)

U.S. Department of Labor
Office of Labor-Management Standards
Cincinnati District Office
36 East Seventh Street, Suite 2550
Cincinnati, OH 45202
(513) 684-6840 Fax: (513) 684-6845

June 14, 2010

Ms. Vickie Napierkowski, Treasurer
Communication Workers Local 4510
PO Box 1525
433 3rd Street
Portsmouth, OH 45662

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LM Number: 518066

Dear Ms. Napierkowski:

This office has recently completed an audit of Communication Workers Local 4510 under the Compliance Audit Program (CAP) to determine your organization’s compliance with the provisions of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). As discussed during the exit interview with you, President Mark Powell, Vice President Carla Womack, and Recording Secretary Star Bell on June 4, 2010, the following problems were disclosed during the CAP. The matters listed below are not an exhaustive list of all possible problem areas since the audit conducted was limited in scope.

Reporting Violations

The audit disclosed a violation of LMRDA Section 201(b), which requires labor organizations to file annual financial reports accurately disclosing their financial condition and operations. The Labor Organization Annual Report Form LM-3 filed by Local 4510 for the fiscal year ended September 30, 2006, was deficient in that Local 4510 reported $520.00 in Item 26 (Loans Receivable) for the end of the reporting period. When we discussed this at the opening interview of this audit, it was discovered that the $520.00 was actually a fund transfer between the local’s general and political accounts, and should not have been reported in Item 26 or anywhere else on the report. You stated that that a former executive board member completed the report and you signed it because you were newly elected and the report was overdue. Based on your assurance that Local 4510 will closely review the Form LM-3 instructions before completing the report each year, OLMS will take no enforcement action at this time regarding the deficient 2006 LM report.

The audit also disclosed a violation of LMRDA Section 201 which requires labor organizations to file annual financial reports within 90 days of the end of each fiscal year. The local was delinquent in filing the Form LM-3 for 2004, 2005, 2006, 2007, 2008, and 2009. For example, the local’s 2009 report was due December 30, 2009, but was not filed until June 4, 2010. Based on your assurance that Local 4510 will timely file its Labor Organization Annual Report Forms in the future, OLMS will take no enforcement action regarding this violation.

I want to extend my personal appreciation to Communication Workers Local 4510 for the cooperation and courtesy extended during this compliance audit. I strongly recommend that you make sure this letter and the compliance assistance materials provided to you are passed on to future officers. If we can provide any additional assistance, please do not hesitate to call.



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cc: Mr. Mark Powell, President